Safety Management System Consensus Standard Public Workshop Announced

PHMSA recently announced a one day public workshop to discuss the development of a safety management system (SMS) national consensus standard for the pipeline industry. In the NTSB’s Investigation of the Marshall, Michigan incident, the agency stated that Enbridge’s centralized safety management system was deficient because it failed to consider the safety of operational processes, such as control center operations and integrity management. In addition, the NTSB found that “pipeline safety would be enhanced if pipeline companies implemented SMSs” and made a recommendation to the American Petroleum Institute (API) to develop a safety management standard specific to pipelines. For that reason, API is currently developing Recommended Practice (RP) 1173 for Pipeline Safety Management Systems, which is expected to be published in 2014. PHMSA Administrator Jeff Wiese has described this standard as predicated on a “plan-do-check-act” model that adds dimensions that are missing from the integrity management regulations with regard to safety culture and processes for risk mitigation tracking and reporting. While some operators already voluntarily implement SMS programs, it is unclear whether PHMSA will require pipeline operators to implement SMS programs and/or incorporate API RP 1173. The workshop, scheduled for February 27, 2014 in Arlington, Virginia, will include discussion on the success of SMS systems in the aviation, chemical, nuclear and health care industries. The meeting agenda will be posted here and the workshop will be webcast to the public.

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The Hunton Andrews Kurth LLP pipeline practice, comprising more than 75 lawyers, has been providing legal advice to the oil and gas industry for over fifty years. We advise and represent numerous oil and gas companies across the US on virtually all types of environmental, regulatory compliance and enforcement defense issues involving the design, siting, construction, testing, operation, maintenance and integrity management of oil and gas pipelines. Our team draws on its strong working relationships with the various federal and state agencies that regulate pipeline activities to manage clients’ evolving legal and business needs as efficiently and effectively as possible. With representations in nearly all 50 states, our depth of experience is matched by our geographical footprint.

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